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December 20, 2017

VIA EMAIL AND U.S. MAIL

Connie Williams, Chief, Program Evaluation and Decision Support

Quality of Information Officer

USDA Animal and Plant Health Inspection Service

4700 River Road, Unit 120

Riverdale, MD 20737

Connie.M.Williams@aphis.usda.gov

(301) 851-3087

RE: COMPLAINT ABOUT INFORMATION QUALITY

Dear Ms. Williams,

PEER respectfully submits this complaint about Data Quality.

Pursuant to Section (b)(2)(B) of the Data Quality Act of 2000 (“DQA”), Section 515 of 

Public Law 106-554, and the Correction of Information mechanism of the U.S. Department of 

Agriculture Information Quality Guidelines, Public Employees for Environmental Responsibility 

(“PEER”) hereby challenges data manipulation and conclusions drawn therefrom by the U.S. 

Department of Agriculture (“USDA”), as detailed infra. PEER is especially concerned about the 

government’s dissemination of faulty research that has been erroneously used to justify harmful,

commonplace, and excessive coyote control and extermination policies throughout federal lands 

despite more recent, thorough, and peer-reviewed scientific studies demonstrating the importance 

of large mammalian carnivores contributing to ecological health and stability. Specifically, 

PEER challenges the government’s continued reliance upon the USDA-funded study Connolly,

G.E., and W.M. Longhurst, 1975, The effects of control on coyote populations: A simulation 

model, University of California, Division of Agricultural Sciences Bulletin, Volume 1872, 37 pp.

(hereinafter “Connolly and Longhurst study”).

The USDA has consistently used this study for over 40 years, despite its established 

flaws and disputed findings, to justify large-scale coyote extermination efforts – even though the 

study’s own findings stated that eradication efforts were not an effective means of preventing 

depredation. In addition to being used to justify large-scale coyote control (i.e., killing 
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programs), this obscure (i.e., a small agricultural bulletin) and non-peer reviewed study has been 

cited and utilized in a variety of USDA documents over the years to justify a variety of agency 

actions related to coyote management. See, e.g., Paul L. Hegdal et al., Hazards to Wildlife 

Associated with 1080 Baiting for California Ground Squirrels, USDA National Wildlife 

Research Center – Staff Publications (1979); Guy E. Connolly, The Effects of Control on Coyote 

Populations: Another Look, Symposium Proceedings—Coyotes in the Southwest: A 

Compendium of Our Knowledge 23 (1995); Kathleen A. Fagerstone and Gail Keirn, Wildlife 

Services—A Leader in Developing Tools and Techniques for Managing Carnivores, USDA 

National Wildlife Research Center – Staff Publications (2012); Eric Gese, Demographic and 

Spatial Responses of Coyotes to Changes in Food and Exploitation, Wildlife Damage 

Management Conferences—Proceedings 131 (2005); John L. Gittleman et al., “References” for 

Carnivore Conservation, USDA National Wildlife Research Center – Staff Publications (2001); 

Gary Lee Nunley, Present and Historical Bobcat Population Trends in New Mexico and the 

West, Proceedings of the 8th Vertebrate Pest Conference 177, 180 (1978); Stewart W. Breck et 

al., Evaluating Lethal and Non-Lethal Management Options for Urban Coyotes (2016); William 

C. Pitt et al., An Individual-Based Model of Canid Populations: Modelling Territoriality and 

Social Structure (2003); USDA, 5 Year Environmental Monitoring Review for Predator Damage 

Management in Montana: FY 2002 through FY 2006 (2007).

Furthermore, USDA has relied upon this study for justification of coyote eradication 

efforts or large scale control (i.e., killing) programs in numerous Environmental Assessments 

and Findings of No Significant Impact under the National Environmental Policy Act, 42 U.S.C. § 

4321, et seq (“NEPA”). This includes, but is not by any means limited to, Final EA: Predator 

Damage and Conflict Management in Idaho (2016); Final EA: Reducing Coyote Damage to 

Livestock and Other Resources in Louisiana (2016); EA: Mammal Damage Management in the 

Commonwealth of Massachusetts (2015); EA: Reducing Mammal Damage in the State of North 

Carolina (2015); EA: Mammal Damage Management in the State of Rhode Island (2014); EA: 

Mammal Damage Management in Arkansas (2013); Decision and Finding of No Significant 

Impact: Reducing Mammal Damage through an Integrated Wildlife Damage Management 

Program in the State of New Jersey (2004); Decision and Finding of No Significant Impact for 

Management of Coyote, Dog, and Red Fox on Livestock in the Commonwealth of Virginia

(2002); Environmental Assessment and Decision/Finding of No Significant Impact for Predator 

Damage Management in the College Station Animal Damage Control District Texas (1997). 

While USDA guidelines limit challenge of material used in NEPA documents to the public 

comment period for each NEPA document, it is evident from the recent and continued use of this 

study in justifying coyote eradication and control efforts that the study is being disseminated by 

the USDA and is clearly influential in both state and federal wildlife agency decision and policymaking, despite its faulty nature.

USDA’s use of the Connolly study violates the requirements of the Data Quality Act and 

as such the study should be removed from use by the agency and notice of its discontinued use 

be distributed among the USDA, Department of Interior (“DOI”) and state game agencies still 

utilizing this study to justify coyote hunting policies and control strategies.
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According to the Information Quality Guidelines, affected persons may avail themselves 

of multiple methods for notifying the USDA of complaints. See USDA, Office of the Chief 

Information Officer, Information Quality Guidelines: Correction of Information, available at 

https://www.ocio.usda.gov/policy-directives-records-forms/guidelines-qualityinformation/correction-information. In accordance with those guidelines, PEER has mailed and 

emailed this complaint to the stated addresses and directed the complaint to Connie Williams, 

Chief Information Officer for the USDA Animal and Plant Health Inspection Service. See id. 

APHIS includes Wildlife Services, the primary USDA component disseminating the Connelly 

and Longhurst study.

I. CHALLENGED INFORMATION DOES NOT COMPLY WITH THE INFORMATION 

QUALITY GUIDELINES

a. Legal Basis for Data Quality Act Challenge

Section 515 of the Treasury and General Government Appropriations Act of 2001 (PL 

106-544, H.R. 5658) directs the Office of Management and Budget (“OMB”) to issue 

government-wide guidelines that “provide policy and procedural guidance to Federal agencies 

for ensuring and maximizing the quality, objectivity, utility, and integrity of information 

(including statistical information) disseminated by Federal agencies.” OMB published final 

guidelines to implement Section 515 in the Federal Register on September 28, 2001, 66 Fed. 

Reg. 49718, (Sep. 28, 2001), and subsequently updated these guidelines on February 22, 2002, 

67 Fed. Reg. 8452 (Feb. 22, 2002).

OMB’s guidelines direct that Federal agencies “shall develop a process for reviewing the 

quality (including the objectivity, utility, and integrity) of information before it is disseminated. 

Agencies shall treat information quality as integral to every step of an agency’s development of 

information, including creation, collection, maintenance, and dissemination.” 67 Fed. Reg. 8452, 

8459 (Feb. 22, 2002). Furthermore, “[t]o facilitate public review, agencies shall establish 

administrative mechanisms allowing affected persons to seek and obtain, where appropriate, 

timely correction of information maintained and disseminated by the agency that does not 

comply with OMB or agency guidelines. These administrative mechanisms shall be flexible, 

appropriate to the nature and timeliness of the disseminated information, and incorporated into 

agency information resources management and administrative practices.” Id.

The purpose of the Data Quality Act was to ensure that the government disseminated the 

best quality information. See 66 Fed. Reg. 49718, 49718 (Sep. 28, 2001). OMB guidelines

require a basic standard of quality. 67 Fed. Reg. 8452, 8458 (Feb. 22, 2002). They also require 

that each agency adopt guidelines appropriate for the information they disseminate. Id. In this 

case, the Department of the Agriculture’s guidelines govern the challenge. USDA, Office of the 
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Chief Information Officer, Information Quality Activities.

1 The Department stated therein that it 

will make sure that information disseminated is accurate, reliable, and unbiased, and will “treat 

information quality as integral to every step in their development of information, including 

creation, collection, maintenance, and dissemination.” USDA Guidelines, Information Quality 

Activities, IQA Main. 

The data disseminated by the USDA must meet requirements of objectivity, utility, and 

integrity. Id. To fulfill agency objectivity requirements, agency information must be 

“substantively accurate, reliable, and unbiased” and the agency must identify such information 

for public review of its objectivity. Id. The USDA assesses the utility of a study based upon its 

internal review of usefulness of the information and requires that disseminated information is 

accessible to all persons. Id.

Among the other standards, the USDA guidelines state that as a general matter, 

scientific and research information that has been subjected to formal, independent, external 

peer review is regarded as presumptively objective. USDA Guidelines, Information 

Quality Activities, Scientific Research. For the peer review process, the USDA guidelines 

require that one or more of the following procedures be used for influential studies:

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1. Conduct a peer review that meets the standards recommended by the OMB 

Bulletin.

i. Where appropriate, subject the information to formal, independent, 

external peer review to ensure its objectivity. If data and analytic 

results have been subjected to such a review, the information may 

generally be presumed to be of acceptable objectivity. However, in 

accordance with the OMB standard, this presumption is rebuttable 

based on a persuasive showing by a petitioner in a particular instance, 

although the burden of proof is on the complainant. 

ii. If agency-sponsored peer review is employed to help satisfy the 

objectivity standard, the review process should meet the general 

criteria for competent and credible peer review recommended by 

OMB. OMB recommends that (a) peer reviewers be selected 

primarily on the basis of necessary technical expertise, (b) peer 

reviewers be expected to disclose to agencies prior technical/policy 

positions they may have taken on issues at hand, (c) peer reviewers be 

expected to disclose to agencies their sources of personal and 

 

1 Available at https://www.ocio.usda.gov/policy-directives-records-forms/information-quality-activities 

2 The challenged Connolly and Longhurst study meets the influential standard as it has been the definitive study 

used by USDA for the past 40 years to establish lethal control policies and has been used by the U.S. Department of 

Interior and state game agencies.
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institutional funding (private or public sector), and (d) peer reviews 

be conducted in an open and rigorous manner.

2. Confirm that the information to be released has been peer reviewed by a 

reputable scientific or professional journal, and the journal has agreed to publish 

the same information. 

3. Conduct an internal review, which for the purposes of establishing 

transparency, ensures that the report or research product clearly states what the 

information and data are, how they were obtained, and any reservations or 

limitations on their use. 

 

USDA Peer Review Implementation Guidelines at 5-6.3 The presumption that peer-reviewed 

material is objective can be rebutted, and non-peer reviewed studies are not considered to be 

presumptively objective. Id; see also 67 Fed. Reg. 8452, 8459 (Feb. 22, 2002). 

The Information Quality Guidelines describe how a challenge to the quality of 

information must proceed. USDA Guidelines, Correction of Information. The challenge must 

have six elements: a statement that the submittal is under USDA’s Information Quality 

Guidelines, a specific reference to the information being challenged, a statement from the 

complainant describing why the information does not satisfy the Department’s or OMB’s 

guidelines, the ways in which the complainant is affected by the information, a recommendation 

and justification for how the information should be corrected, and the name, address and other 

contact information of the complainant. Id. All these requirements are satisfied in this letter. 

PEER’s name, address, phone number, fax number and email address is provided, the 

specific study is cited above, and the complainant is affected in ways described in Part III of this 

letter. Additionally, the challenged information violates the standards of data quality because it 

lacks the baseline reliability quality required by statute. “Quality” as a term encompasses utility, 

objectivity, and integrity. 67 Fed. Reg. 8452, 8459 (Feb. 22, 2002). As it relates to quality, 

utility refers to “the usefulness of the information to its intended users, including the public. In 

assessing the usefulness of information that the agency disseminates to the public, the agency 

needs to consider the uses of the information not only from the perspective of the agency but also 

from the perspective of the public.” Id. (emphasis added). Furthermore, “when transparency of 

information is relevant to assessing the information’s usefulness from the public’s perspective, 

the agency must take care to ensure that transparency has been addressed in its review of the 

information.” Id. In this case, the information challenged herein is of limited utility due to its 

age, lack of transparency, and the numerous recent peer-reviewed publications rebutting its

erroneous conclusions. It can no longer reasonably be used to inform the government’s

carnivore control policy. Furthermore, even if a challenged study has been through the peer 

review process (which this study and its 1995 review by its principal researcher do not appear to 

 

3 USDA, Office of the Chief Information Officer, USDA’s Peer Review Guidelines, available at 

https://www.ocio.usda.gov/document/usdas-peer-review-guidelines. 
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have been), its presumption of objectivity may be rebutted with a showing by a petitioner. 67 

Fed. Reg. 8452, 8459 (Feb. 22, 2002). The information provided by this study is not reliable or 

accurate; thus even if it were peer-reviewed, the presumption in its favor would be rebutted. 

b. Issues with the Quality of the USDA Research

The Connolly and Longhurst study lacks utility for USDA’s intended purpose of evaluating and

authorizing large-scale coyote extermination.

By repeatedly using the Connolly and Longhurst study for more than 40 years, USDA

continues to rely on its findings as scientific evidence justifying large-scale coyote extermination

programs, killing 76,859 coyotes in 2016 alone.

4 The study has been relied on to support a claim 

of population resiliency in explosives and poison usage assessments, population modeling 

publications, NEPA documents for lethal control programs, and efficacy reviews for various 

carnivore management tactics, as well as a variety of other agency documents. In other words, 

USDA has justified exterminating coyotes on the basis of the study’s questionable conclusion 

that coyote populations rebound after major extermination events – while ignoring the ultimate 

conclusion of the study that lethal management of coyotes is not an effective method for

reducing coyote populations or depredation events. Not only has USDA employed this study for 

internal purposes, it has disseminated this study to state game agencies and the DOI for use in 

their hunting program environmental assessments and planning materials. 

However, it is abundantly clear that this study is no longer useful, due to its age and 

countless errors (discussed in detail below). Even apart from these flaws, USDA misuses the 

study to justify a practice that the study actually recommends against. The study that USDA uses 

to justify broad lethal control of coyotes actually describes the futility of killing coyotes for 

management purposes since the species will simply rebound in numbers in a short period of time 

(<3 years) due to density dependent responsive reproduction. In fact, the authors finished their 

paper by concluding that they “emphatically do not recommend eradication as the preferred 

coyote management strategy . . . Killing coyotes unselectively . . . is not a very feasible means of 

reducing populations over broad geographical areas.” Connolly and Longhurst at 32-33

(emphasis added). Rather than providing justifications for coyote killing, the authors 

“suggest[ed] that other means should be found to reduce coyote depredations, and that better 

understanding of coyote population dynamics is required.” Connolly and Longhurst at 33. We 

now understand more about coyote population dynamics.

Moreover, this study, which is relied upon so heavily by not just the USDA but also the 

DOI and numerous state game agencies,5is based on speculative – not empirical – data from the 

 

4 See https://www.aphis.usda.gov/wildlife_damage/pdr/PDR-G_Report.php?fld=&fld_val=

5 As state game agencies often rely upon federal data and research to establish lethal control guidelines and hunting 

regulations, USDA and DOI reliance upon this study has significantly impacted state management of wildlife. See, 

e.g., Strawberry Valley Greater Sage-Grouse (Centrocercus Urophasianus) Local Conservation Plan (2006); 
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1970s. In fact, when discussing birth and death functions, the authors feel compelled to 

“reemphasize that the form of these functions is largely speculative.” Connolly and Longhurst at 

15 (emphasis added). This paper is over 40 years old and reams of scientific data on coyotes and 

predators in general have been produced since then.

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It is questionable at best, and dishonest at worst, for USDA and other agencies to 

continue to rely on this 42 year old model, based on “largely speculative” data. Even the authors 

seem to acknowledge the unsuitability of using their work to justify lethal control by saying, 

“[s]ince reliable estimates of coyote numbers are notoriously difficult to obtain, the information 

needed to plan intelligent predator management programs is not usually available. In most areas 

we simply do not know how the control kill relates to the size of the population, or even whether 

coyote numbers are increasing or decreasing.” Connolly and Longhurst at 27. Not only does 

recent research demonstrate that lethal control programs have detrimental ecological effects, but 

it reinforces the missed message of the Connolly and Longhurst study that lethal control of 

carnivores is not an effective tactic for combating livestock depredation. See Treves, A., M.

Krofel and J. McManus (2016), Predator control should not be a shot in the dark, Frontiers in 

Ecology and the Environment 14: 380–388; Van Eeden, L. M., et al. (2017), Managing conflict 

between large carnivores and livestock, Conservation Biology, doi: 10.1111/cobi.12959.

Considering the fact that a tremendous volume of coyote research and data has emerged since the 

1970s (including birth rates, age ratios, survival, effects of hybridization, etc.), the Connolly and 

Longhurst study has been rendered useless and antiquated for purposes of scientifically sound 

coyote control and hunting decisions. 

Furthermore, the Connolly and Longhurst study is cited by USDA materials to 

erroneously reach broad conclusions about management of coyotes in the eastern U.S., such as 

the acceptability of large scale lethal management programs7and the efficacy of lethal control8,

despite this region possessing a different population of canids, namely the eastern coyote, or 

coywolf, a hybridized subspecies with only roughly 60% shared genetics with western Canis 

latrans. Neither PEER nor its coyote researcher collaborators have been able to locate any 

USDA, or more specifically Wildlife Services, documents that effectively address the 

reproductive and behavioral differences between the western Canis latrans and the eastern

coyote, whose reproductive rates and behavior often resembles the wolf, Canis spp. (lycaon or

lupus), with which it shares roughly 30% of its genetics. This manifests in the eastern coywolf 

possessing delayed sexual maturity, smaller litter size, larger territories, and differences in prey 

preference when compared to western Canis latrans. See Way, J.G. and Lynn, W.S., 

Northeastern coyote/coywolf taxonomy and admixture: A meta-analysis, Canid Biology & 

Conservation 19(1): 1-7 (2016); http://canids.org/CBC/19/Northeastern_coyote_taxonomy.pdf.

 

Nevada Animal Damage Control Program 2005 Work Plan for Nevada Public Lands (2005); Southeastern Arizona 

Wild Turkey Management Plan (2000).

6 See Appendix. A.

7 See e.g., Decision and Finding of No Significant Impact: Reducing Mammal Damage through an Integrated 

Wildlife Damage Management Program in the State of New Jersey (2004).

8 See, e.g., Stewart W. Breck et al., Evaluating Lethal and Non-Lethal Management Options for Urban Coyotes

(2016).
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Therefore, the challenged study lacks utility in predator management decisions and studies for 

large parts of the U.S. where hybridized eastern coyote/coywolf populations have replaced Canis 

latrans populations; yet USDA usage and dissemination of this material does not reflect these 

differences.

USDA’s use of the Connolly and Longhurst study lacks objectivity because the study is 

inaccurate and unreliable. 

Despite being outdated and not peer reviewed, the Connolly and Longhurst study 

continues to be used to support decisions by federal and state agricultural departments and 

wildlife agencies promoting the unlimited slaughter of coyotes nationwide. Specifically, agency 

studies and decisions are justified by Connolly and Longhurst’s speculative finding that “coyotes 

through compensatory reproduction can withstand an annual control level of 70%.” Connolly 

and Longhurst at 19.9 Yet, while agencies continue to rely on this study, the substance remains 

inaccurate, unreliable, and biased. Inaccuracies throughout the study affect both models and 

conclusions. This is seen early on in the study when the author states that “in the model, both 

control and natural losses are calculated once each year[,]” However, earlier in the paper, it is 

mentioned that losses occur throughout the year, making reliance on data calculated once a year 

unsound. Connolly & Longhurst at 3. While it is just a model, having only one mortality event is 

highly inaccurate given that deaths occur throughout the year (Parker 1995), and such an 

inaccuracy could clearly affect population models. See G.R. Parker, Eastern Coyote: The Story 

of Its Success (1995), Nimbus Publishing, Halifax, NS.

Recent research and data on coyotes has revealed the information set forth in the 

Connolly and Longhurst study to be even more inaccurate than it appeared at the time. Figure 3

of the study, charting coyote litter size related to coyote density, is just one example of such an 

inaccuracy revealed by recent data. Connolly & Longhurst at 10. The corresponding text states 

that coyote litter size increases with additional control. While Knowlton (1972) noted that 

average litter size varied inversely with density of coyotes whereby lower populations of coyotes 

(i.e., ones that were subjected to human lethal control) had higher litter sizes (and cited in 

Connolly and Longhurst 1975), more recently, Crabtree and Sheldon (1999) suggested that litter 

survival and not litter size at birth is the major reproductive parameter that responds to human 

exploitation in a density-dependent manner because litter size varied little with prey abundance. 

 

9 See USDA, 5 Year Environmental Monitoring Review for Predator Damage Management in Montana: FY 2002 

through FY 2006 (2007), 3-4; Paul L. Hegdal et al., Hazards to Wildlife Associated with 1080 Baiting for California 

Ground Squirrels, USDA National Wildlife Research Center – Staff Publications (1979) at 34. See also, Final EA: 

Predator Damage and Conflict Management in Idaho (2016); Final EA: Reducing Coyote Damage to Livestock and 

Other Resources in Louisiana (2016); EA: Mammal Damage Management in the Commonwealth of Massachusetts

(2015); EA: Reducing Mammal Damage in the State of North Carolina (2015); EA: Mammal Damage Management 

in the State of Rhode Island (2014); EA: Mammal Damage Management in Arkansas (2013); Decision and Finding 

of No Significant Impact: Reducing Mammal Damage through an Integrated Wildlife Damage Management 

Program in the State of New Jersey (2004); Decision and Finding of No Significant Impact for Management of 

Coyote, Dog, and Red Fox on Livestock in the Commonwealth of Virginia (2002); Environmental Assessment and 

Decision/Finding of No Significant Impact for Predator Damage Management in the College Station Animal 

Damage Control District Texas (1997).
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See R.L. Crabtree and J.W. Sheldon, Coyotes and Canid Coexistence in Yellowstone (1999); F.F. 

Knowlton, Preliminary Interpretations of Coyote Population Mechanics with Some Management 

Implications, 36 J. Wildlife Mgmt. 369 (1972). In sum, recent research clearly shows that litter 

survival over time is a more robust indicator of mortality rates than litter birth size. This is 

particularly relevant to the contents of the challenged study as coyote populations are selfregulated by prey availability and territoriality (i.e., guarding home range areas from other 

packs); as a result, litter survival is directly related to artificially lowered population densities

caused by lethal control.

This simply means that, on average, coyote litter size changes minimally following an 

increase in mortality, but litter survival over time does improve with increased mortality, which 

likely compensates for reduced survival of adults. A simple mechanism to explain this is that 

there is a greater energy cost to successfully raise offspring than to produce them, and increased 

mortality of adults likely causes the food supply to increase in an area, allowing for greater litter 

survival. While it is important to stress how vigorously coyote populations compensate for 

population reductions, this is a common characteristic for a density dependent (i.e., territorial) 

species. See R. Crabtree, Scientific Opinion Letter for Predator Defense: “What Effect does 

Reduction of Coyotes (older than 6 months) have on the Remaining Population?” (1997, revised 

2012), http://predatordefense.org/docs/coyotes_letter_Dr_Crabtree_06-21-12.pdf. However, the 

bottom line is that if litter sizes do not increase to the degree stated in Figure 3, then there will be 

less coyotes born and hence a smaller population size and population recovery under Connolly 

and Longhurst’s model.

Furthermore, it is evident that the Connolly and Longhurst study lacks an acceptable level 

of objectivity because the experimental design of the study specifically seeks to model how to 

effectively eradicate coyote populations for the benefit of livestock producers. Therefore, the 

study has a built-in bias favoring eradication. It also lacks the benefit of a growing body of 

subsequently developed evidence of the negative ecological and behavioral consequences of 

carnivore hunting and eradication programs. See Estes, J.A., et al. 2011. Trophic downgrading of 

planet earth. Science 333: 301–306; Gilbert et al. 2016, Socioeconomic benefits of large 

carnivore recolonization through reduced wildlife-vehicle collisions, Conservation Letters DOI: 

10.1111/conl.12280; Ripple et al. 2014, Status and ecological effects of the world’s largest 

carnivores, Science 343: 151–162; Robinson et al. 2008, Sink populations in large carnivore 

management: cougar demography in a hunted population, Ecological Applications 18(4): 1028-

1037. Hunting pressure on large carnivore populations can have disruptive effects on social 

structure, movement patterns, and behavior, which can undermine their ecological role as 

predators. Ordiz et al., 2013, Saving large carnivores, but losing the apex predator? Biological 

Conservation 168: 128-133. Moreover, heavily hunted wolves have higher stress and 

reproductive steroids/hormones than individuals with lower hunting pressure, supporting the 

theory of social and physiological consequences to sentient animals, like canids, of humancaused mortality such as sport hunting. Bryan, H., et al., Heavily hunted wolves have higher 

stress and reproductive steroids than wolves with lower hunting pressure, Functional Ecology, 

2014, 1-10, doi: 10.1111/1365-2435.12354. Lethal control programs targeting coyotes can also 

disrupt population dynamics for other, smaller predators, resulting in increased predation and 

nest failure for species like the greater sage-grouse. Mezquida et al., 2006, Sage-Grouse and 
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Indirect Interaction: Potential Implications of Coyote Control on Sage-Grouse Populations, 

Condor 108.4, 747-759. The authors of this study noted that the effects of stress are often subtle, 

but the resulting harm can be acute, chronic, and permanent, sometimes spanning generations. Id.

Additionally, recent research suggests that lethal control may generate public opposition 

to wildlife managers, undermine positive attitudes toward wildlife and result in the devaluation 

of large carnivores such as wolves and coyotes. Bruskotter, J. T., J. J. Vaske, and R. H. Schmidt. 

2009, Social and Cognitive Correlates of Utah Residents' Acceptance of the Lethal Control of 

Wolves, Human Dimensions of Wildlife 14:119-132; Treves A., L. Naughton-Treves, and V. 

Shelley, 2013, Longitudinal analysis of attitudes toward wolves, Conservation Biology 27: 315-

323; Treves, et al., 2015, Predators and the Public Trust, Biological Reviews 92: 248-270. 

Research has discovered that American public acceptance of lethal methods of predator control 

has declined over the past two decades, with people increasingly finding lethal methods 

inhumane. Slagle et al., 2017, Attitudes toward predator control in the United States: 1995 and 

2014, Journal of Mammalogy, 98, 7-16. In fact, a study in Massachusetts found that voters 

overwhelmingly opposed coyote hunting practices once they became aware of them. Jackman, J. 

L., and J. G. Way, 2017, Once I found out: Awareness of and attitudes toward coyote hunting 

policies in Massachusetts, Human Dimensions of Wildlife, DOI: 

10.1080/10871209.2017.1397824. Thus, the American Society of Mammalogists recently 

published a series of papers presenting new evidence of the greater efficacy and social 

acceptability of nonlethal deterrents to livestock depredation by large carnivores, as well as the 

lack of justification for and possible harm to populations and ecosystems resulting from lethal 

control of these predators. Bergstrom, B.J., 2017, Carnivore conservation: shifting the paradigm 

from control to coexistence, Journal of Mammalogy 98: 1-6. This followed research by Treves et 

al. (2016) that recommended suspending lethal predator control methods, especially by publicly 

funded government programs, which do not currently have rigorous evidence for functional 

effectiveness in preventing predation, until gold-standard tests are completed. Treves, A., M. 

Krofel, and J. McManus, 2016, Predator control should not be a shot in the dark, Frontiers of 

Ecology and Environment 14(7): 380–388, doi:10.1002/fee.1312. Reliance on the outdated 

Connelly and Longhurst study results in ignoring all of this more recent research and its 

conclusions.

In sum, due to advances in coyote and carnivore research, the antiquated Connolly and 

Longhurst data is largely unreliable and lacks utility for making determinations regarding 

coyotes. Its use must be discontinued to achieve compliance with USDA Information Quality 

guidelines.

II. THE CHALLENGED INFORMATION IS INFLUENTIAL AND MUST MEET 

HIGHER STANDARDS

In addition to not meeting the basic standards stated above, the Connolly and Longhurst 

study does not meet the higher standards for influential information. Information is influential 

when it is has a broad impact, such as affecting a wide range of parties (i.e., an entire industry), 
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rather than solely one company, and when its impact is intense, meaning that it has a large 

impact on affected parties. USDA Guidelines, Background, USDA's Definition of Influential 

Scientific, Financial, or Statistical Information.

10

 

Under the USDA definition, the Connolly and Longhurst study is undoubtedly influential 

in agency decision making. It has affected a broad range of parties, from wildlife biologists and 

veterinarians to farmers and loggers, as well as wildlife enthusiasts and visitors to public lands.

It has had an intense impact, illustrated by the fact that USDA Wildlife Services spent over $1.13 

billion in federal tax dollars on wildlife extermination efforts between 2004 and 2013.11 The 

disputed study has informed coyote lethal control efforts and carnivore hunting policy for 

decades, despite being outdated and not peer reviewed, by being eternally regurgitated to support

killing of up to 70% of a coyote population.

12 Furthermore, due to USDA’s consistent reliance 

upon this study, its dissemination by this agency has also resulted in the widespread use of this 

study to establish liberal and excessive coyote and coywolf hunting policies by DOI and state 

game agencies across the country. See e.g., Ronald A. Thompson, The Cost of Predator Damage 

Control Using Trapping as the Primary Control Technique, Proceedings of the 7th Vertebrate 

Pest Conference 146 (1976); National Park Service, Cape Cod National Seashore Hunting 

Program, Final Environmental Impact Statement, Cape Cod National Seashore, MA, 72 Fed. 

Reg. 44,176 (Aug. 7, 2007); EA: Mammal Damage Management in the Commonwealth of 

Massachusetts (2015). This dissemination to other federal and state agencies is significant and 

influential since Wildlife Services maintains a very close working relationship with state 

agriculture and wildlife agencies. See, USDA APHIS Wildlife Services Directive, 3.101 and

3.102.

The USDA’s Office of Inspector General formally acknowledges on its website that 

“influential information is subject to an added level of scrutiny.”13 According to the Department 

of the Agriculture’s guidelines, influential scientific information related to human health, safety,

and the environment must “use the best available science and supporting studies conducted in 

accordance with sound and objective scientific practices,” and “use data collected by accepted 

methods or best available methods.” USDA Guidelines, Scientific Research, Part II. As a 42 year 

old non-peer reviewed speculative modeling study, it is evident that the Connolly and Longhurst 

 

10 Available at https://www.ocio.usda.gov/policy-directives-records-forms/guidelines-qualityinformation/background

11 See http://www.humanesociety.org/assets/pdfs/wildlife/USDA-wildlife-services-kill-data-2004-2013.pdf

12 See e.g., FN5 supra, USDA, 5 Year Environmental Monitoring Review for Predator Damage Management in 

Montana: FY 2002 through FY 2006 (2007), 3-4; See also, Final EA: Predator Damage and Conflict Management 

in Idaho (2016); Final EA: Reducing Coyote Damage to Livestock and Other Resources in Louisiana (2016); EA: 

Mammal Damage Management in the Commonwealth of Massachusetts (2015); EA: Reducing Mammal Damage in 

the State of North Carolina (2015); EA: Mammal Damage Management in the State of Rhode Island (2014); EA: 

Mammal Damage Management in Arkansas (2013); Decision and Finding of No Significant Impact: Reducing 

Mammal Damage through an Integrated Wildlife Damage Management Program in the State of New Jersey (2004); 

Decision and Finding of No Significant Impact for Management of Coyote, Dog, and Red Fox on Livestock in the 

Commonwealth of Virginia (2002); Environmental Assessment and Decision/Finding of No Significant Impact for 

Predator Damage Management in the College Station Animal Damage Control District Texas (1997).

13 Office of Inspector General Information Quality Guidelines, Standards for Disseminated Information, 

http://www.usda.gov/oig/qltyguidelinesrev.htm.
12

study does not come close to meeting the USDA’s requirements for the use of the best available 

science nor does it reflect data collected through the best available methods. Over the past 42 

years, there have been significantly more detailed and academically rigorous studies dealing with 

coyote reproduction, population density, efficacy of lethal control, and effects of hybridization 

on canid populations.14 Therefore, USDA lacks any justifiable reason to continue reliance upon 

this study in its decision-making concerning lethal control of coyote populations.

USDA’s Data Quality Act standards also require USDA to “[d]isseminate influential 

scientific information with a high degree of transparency about data and methods to facilitate its 

reproducibility by qualified third parties.” Id. However, the challenged study is not readily 

available to the public and PEER was only able to obtain a copy of this study through an interlibrary loan with the University of Arkansas, seemingly the only place where this study could be 

found, as it was unavailable on any USDA website, common research databases, or the broader 

internet.

Based on the allegations above, it is clear that the USDA has developed its coyote control 

and hunting policies relying upon outdated information from the challenged study that is not the 

“best available science.” Because it is influential information, the agency must review the paper

with heightened scrutiny, which should result in not using it in future documents, and retracting

it from previous ones.

III. PETITIONERS ARE AFFECTED BY THE INFORMATION ERRORS

Public Employees for Environmental Responsibility (“PEER”) is a non-profit public 

interest organization incorporated in Washington, D.C. and headquartered in Silver Spring, 

Maryland, with field offices in California, Colorado, Florida, Massachusetts, and Tennessee. 

Among other public interest projects, PEER engages in advocacy, research, education, and 

litigation to promote public understanding and debate concerning key current environmental 

policy issues. PEER focuses on the environment, including the regulation and remediation of 

toxic substances, public lands, natural resource and wildlife management, public funding of 

environmental and natural resource agencies, scientific integrity, and ethics in government. 

Furthermore, PEER members include wildlife biologists who study large mammalian carnivores 

and are directly impacted by the USDA’s reliance upon and dissemination of improper data to 

establish coyote eradication, control, and hunting policies.

Additionally, the policy undergirded by the challenged study touches on a number of 

PEER’s traditional concerns. Natural resource management, management of public lands and 

public trust resources including wildlife, and environmental stewardship more generally are all 

implicated by predator management by the USDA. PEER believes that the USDA has not

utilized the best available science, as required by law, in developing an appropriate, sciencebased strategy for managing and considering the ecological importance of carnivores, such as 

 

14 See Appendix A.
13

coyotes. Nor has the agency considered the importance of undisturbed populations of carnivores 

on the ecosystem or the ecological stability of agricultural lands and their surrounding 

environments. PEER values the presence of wild animals necessary for a healthy environment. 

While PEER supports management efforts backed by sound scientific principles, the USDA’s 

current reliance on unreliable information has led to the mismanagement of a group of wild 

carnivores that PEER has an interest in protecting.

The Humane Society of the United States (“The HSUS”) is the nation’s largest animal 

protection organization, headquartered in Washington, D.C. Since its establishment in 1954, The 

HSUS has worked to combat animal abuse and exploitation and promote animal welfare through 

research, public outreach and education, advocacy and litigation. The HSUS strives to protect 

wildlife and improve wildlife management throughout the country, and has long advocated 

coexistence and nonlethal alternatives to predator control, which often relies on inhumane 

techniques such as leg-hold traps, snares, and poisons like sodium cyanide, sodium nitrate and 

Compound 1080. USDA’s continued reliance on and dissemination of the challenged 

information harms The HSUS and its members’ interest in native carnivore conservation and 

prevention of animal suffering by promoting lethal predator control in a manner that is not 

supported by the best available science.

Predator Defense is a national nonprofit advocacy organization funded primarily by 

member donations. It promotes non-lethal predator control that helps people and preserves 

wildlife, as well as monitors and challenges state and federal wildlife management policies that 

adversely affect predator species. Predator Defense works with these agencies in their efforts to 

protect native predators and when necessary, pursues litigation that requires agencies to follow 

laws and regulations established to protect native predators.

Project Coyote is a national non-profit organization based in Northern California whose 

mission is to promote compassionate conservation and coexistence between people and wildlife 

through education, science and advocacy. Its representatives, advisory board members and 

supporters include scientists, educators, ranchers and citizen leaders who work together to 

change laws and policies to protect native carnivores from abuse and mismanagement, 

advocating coexistence instead of killing. Project Coyote seeks to change negative attitudes 

toward coyotes, wolves and other misunderstood predators by replacing ignorance and fear with 

understanding, respect and appreciation.

The Center for Biological Diversity believes that the welfare of human beings is deeply 

linked to nature — to the existence in our world of a vast diversity of wild animals and 

plants. Because diversity has intrinsic value, and because its loss impoverishes society, CBD 

works to secure a future for all species, great and small, hovering on the brink of extinction. 

CBD does so through science, law and creative media, with a focus on protecting the lands, 

waters and climate that species need to survive.

The Animal Legal Defense Fund’s mission is to protect the lives and advance the 

interests of animals through the legal system. ALDF accomplishes this mission by filing high-
14

impact lawsuits to protect animals from harm, providing free legal assistance and training to 

prosecutors to assure that animal abusers are punished for their crimes, supporting tough animal 

protection legislation and fighting legislation harmful to animals, and providing resources and 

opportunities to law students and professionals to advance the emerging field of animal law.

Since its founding in 1951, Animal Welfare Institute has sought to alleviate the suffering 

inflicted on animals by people. A major AWI effort is the quest to end the torture inflicted on 

furbearing animals by steel jaw leghold traps and wire snares.

The National Wolfwatcher Coalition is a 501(c)(3) nonprofit, all volunteer organization. 

It educates, advocates, and participates for the long term recovery and the preservation of wolves 

based on the best available science and the principles of democracy. NWC educates the public, 

advocates for science-based decision making at every level of government and participate in 

activities that promote citizens’ awareness and participation in the decision-making process 

about wolves. It is a moderate organization that seeks to (1) find common ground among all 

stakeholders and (2) encourage solutions to roadblocks that challenge wolf recovery.

Western Watersheds Project is a nonprofit environmental conservation group with 

1,500 members founded in 1993 and has field offices in Idaho, Montana, Wyoming, Arizona, 

Utah, Nevada and California. WWP works to influence and improve public lands management 

throughout the West with a primary focus on the negative impacts of livestock grazing on 250 

million acres of western public lands, including harm to ecological, biological, cultural, historic, 

archeological, scenic resources, wilderness values, roadless areas, Wilderness Study Areas and 

designated Wilderness.

Protect the Wolves is a Native American Religious 501(c)(3) nonprofit that uses Tribal 

Treaty Rights to speak for wildlife. It hosts a wolf sanctuary where wolves can reside in a safe 

place, fights for the end of lethal control efforts on public lands, and promotes responsible 

animal husbandry practices in order to avoid conflicts between ranchers and wolves.

Coyote Watch Canada is a Federal Not-For-Profit community-based, wildlife 

organization which advocates positive human wildlife experiences. It collaborates with a broad 

range of stakeholders to develop and implement of non-lethal, sustainable human-wildlife 

conflict solutions. The organization provides educational programming, a first-response team, 

on-site investigation, assessment and mitigation directives, wildlife rescue and release assistance, 

private, municipal- and provincial-level consultation, digital mapping programs, training, 

educational resources, and municipal wildlife framework models.

Public Lands Media is an independent, non-partisan, source of ecological and 

conservation information. Its staff research, write, and publish articles, essays, and editorials on a 

variety of natural resource/environmental topics. PLM also provides information and assistance 

and links to scientists, the public, conservation groups and others so they can make better 

informed decisions on complex ecological issues. The organization’s goal is to provide 

scientifically informed perspectives on current conservation/environmental issues.
15

WildLands Defense’s activists’ and supporters’ on-the-ground presence, extensive 

experience enforcing existing statutory and regulatory regimes, and the group’s unparalleled 

conviction provide managers and policy-makers a clear and competent picture of the conditions 

of our public lands and wildlife communities on the ground as they exist, as well as lend 

decision-makers the sense of informed urgency as to the need for policy changes into the future.

In Defense of Animals is an international animal protection organization with over 

250,000 valued supporters and a 30-year history of protecting animals, people and the 

environment through education, campaigns and hands on rescue facilities. It educates and 

exposes animal abuse as a root cause, symptom, and early predictor of wider societal violence. 

Its staff advocate change in laws, human behavior, and enlightenment in the need to protect lives, 

advance rights, improve welfare, and steward environmental protection. IDA cares for and 

rehabilitates lost, orphaned, abandoned, and abused animals inside three main sanctuaries.

Center for Ecosystem Restoration is a non-profit organization headquartered in Wickford, 

R.I. that develops and leads projects and partnerships among local citizens, businesses, nonprofit organizations and government agencies. Its goal is to help communities accomplish local 

environmental and economic priorities through ecological restoration. It provides resources to 

accomplish that work through technical support, grant-writing and funding development, 

outreach and other means.

Raincoast Conservation Foundation is a team of conservationists and scientists 

empowered by their research to protect the lands, waters and wildlife of coastal British 

Columbia. They use rigorous, peer-reviewed science and community engagement to further our 

conservation objectives. As a charitable, non-profit conservation science organization that 

operates a research lab, research field station and a research/sailing vessel, Raincoast is unique in 

Canada.

Founded in 1969 in Canada and in the UK in 1981, the International Fund for Animal 

Welfare saves individual animals, animal populations and habitats all over the world. With 

projects in more than 40 countries, IFAW provides hands-on assistance to animals in need, 

whether it’s dogs and cats, wildlife and livestock, or rescuing animals in the wake of disasters. 

IFAW also advocates saving populations from cruelty and depletion, such as its campaign to end 

commercial whaling and seal hunts.

Alongside the listed organizational petitioners, petitioners include a number of the 

foremost researchers and advocates in the field of wildlife, carnivore, and canid conservation 

and/or research. As such, the continued use of faulty research to justify Agency policy directly 

impacts their interests.

IV. RECOMMENDATIONS FOR CORRECTION OF THE INFORMATION 

CHALLENGED BY THIS COMPLAINT

Accordingly, PEER respectfully requests the USDA APHIS take the following steps to 

comply with the Data Quality Act: 
16

1. Retract from current and future agency usage the USDA-funded study: Connolly, G.E., and 

W.M. Longhurst, 1975, The effects of control on coyote populations: A simulation model, 

University of California, Division of Agricultural Sciences Bulletin, Volume 1872, 37 pp.

2. Issue a public statement explaining the reasons for this retraction. 

3. Send a letter to other relevant USDA offices, the Department of Interior, and all state game 

agencies requesting that they refrain from relying on this retracted study for any regulatory or 

public health purpose.15

Please let us know if you require any additional information in support of this complaint 

or if there is any aspect of it that requires clarification. 

Respectfully submitted,

Adam Carlesco, Staff Counsel

Public Employees for Environmental Responsibility

962 Wayne Ave, Suite 610

Silver Spring, MD 20910 

Tel: 202.265.7337

Fax: 202.265.4192

Email: acarlesco@peer.org

Jonathan G. Way, Ph.D.

Founder of Eastern Coyote/Coywolf Research

Co-Author of Carnivore Conservation Act of Massachusetts

 

15 In addition to continuous use by USDA, federal agencies within DOI and state game agencies have consistently 

relied upon this study or USDA NEPA material citing this study to justify large-scale coyote extermination and 

control efforts in planning and management documents. As these DOI documents utilizing this study would be 

subject to challenge during their respective comment periods, the USDA should avoid the vulnerability of numerous 

EAs by withdrawing the study from further use. Despite the plethora of data and studies that have emerged in recent 

years, federal and state game agencies continue to use a 40 year old, non-peer reviewed study for new environmental 

assessments to justify large-scale extermination and loosely regulated hunting of coyote populations. See e.g.,

National Park Service, Cape Cod National Seashore Hunting Program, Final Environmental Impact Statement, 

Cape Cod National Seashore, MA, 72 Fed. Reg. 44,176 (Aug. 7, 2007); Bureau of Land Management, Predator 

Hunt Derby #DOI-BLM-ID-I000-2014-0002-EA, Nov. 2014, https://eplanning.blm.gov/epl-frontoffice/projects/nepa/39720/51280/55821/SRP_Derby_EA_Final_508.pdf; Nevada Animal Damage Control 

Program 2005 Work Plan for Nevada Public Lands (2005). 
17

Osterville, MA

Louise Kane, J.D.

Justice for Wolves and Co-Author of Carnivore Conservation Act of Massachusetts

Eastham, MA

Co-Signatories:

Scientists and Advocates

Jane Goodall, Ph.D., DBE

Founder, the Jane Goodall Institute

United Nations Messenger of Peace

Carter Niemeyer

U.S. Fish and Wildlife Service Biologist, Wildlife Services (retired)

Boise, Idaho

Adrian Treves, Ph.D.

Professor, Nelson Institute for Environmental Studies

University of Wisconsin–Madison

Robert Wielgus, Ph.D.

Professor, Director of the Large Carnivore Conservation Lab

Washington State University

Marc Bekoff, Ph.D.

Professor Emeritus of Ecology and Evolutionary Biology

University of Colorado, Boulder

Bradley J. Bergstrom, Ph.D.

Professor of Biology

Valdosta State University

Alexandra Horowitz, Ph.D.

Adjunct Associate Professor, Canid Cognition

Barnard College

Paul Paquet, Ph.D

Large Carnivore Biologist 

Canada 

Garrick Dutcher

Research and Program Director

Living with Wolves

Doug Peacock 

President, Save the Yellowstone Grizzly 

Board Chair, Round River Conservation Studies

Emigrant, Montana
18

Robin Bruckner

NOAA Habitat Biologist (retired)

Silver Spring, Maryland

John Maguranis

Project Coyote, Massachusetts Representative

Belmont Animal Control Officer

Founding Board Member for Missing Dogs Massachusetts

Waltham, Massachusetts

David Parsons

Carnivore Conservation Biologist

The Rewilding Institute

Albuquerque, NM

Laela Sayigh

Biologist, Woods Hole Oceanographic Institution

Woods Hole, Massachusetts

Virginia Fuller

Former President, New England Wildlife Center

Belmont, Massachusetts

Mike Ruzich

Science teacher, B.S. Biology 

Contributed to and modeled International Wolf Center’s “Of Wolves and Gray Matter” curriculum. 

Ely, Minnesota (in Superior National Forest on the edge of the Boundary Waters Canoe Area, in the 

middle of wolf Country)

Organizations

The Humane Society of the United States

1255 23rd Street, NW, Suite 450 

Washington, DC 20037

Predator Defense 

Brooks Fahy, Executive Director

P.O. Box 5446

Eugene, Oregon 97405

brooks@predatordefense.org

Project Coyote

Camilla H. Fox, Founder & Executive Director

P.O. Box 5007 

Larkspur, California 94977

Center for Biological Diversity

P.O. Box 710

Tucson, Arizona 85702-0710
19

Animal Legal Defense Fund

Stephen Wells, Executive Director

525 E Cotati Ave 

Cotati, California 94931

Animal Welfare Institute

Nancy Blaney, Director of Government Affairs

900 Pennsylvania Ave., SE

Washington, DC 20003

International Fund for Animal Welfare

Carson Barylak, Campaigns Officer

1400 16th Street, NW, Suite 510

Washington, DC 20036

National Wolfwatcher Coalition

Nancy Warren, Executive Director 

Duluth, Minnesota

Western Watersheds Project

Eric Molvar, Executive Director

126 S. Main St, Ste B2

P.O. Box 1770

Hailey, Idaho 83333

Protect The WolvesTM

Patricia Herman, President

Roger Dobson, Director

18175 Hayes Way

Cottonwood, California 96022

Coyote Watch Canada - Community Outreach Team

Lesley Sampson, Founding Executive Director

266 Four Mile Creek Rd

Niagara-on-the-Lake, ON L0S 1J0

Public Lands Media 

George Wuerthner

Bend, Oregon

WildLands Defense

Natalie Ertz, Executive Director

Hailey, Idaho

In Defense of Animals

President Marilyn Kroplick, MD

Lisa Levinson, Sustainable Activism Campaign Director

San Rafael, California
20

Center for Ecosystem Restoration

Thomas Ardito, Director

Saunderstown, Rhode Island

Northeast Oregon Ecosystems

Wally Sykes, Director 

Joseph, Oregon

captmayo@eoni.com

Raincoast Conservation Foundation

Chris Genovali, Executive Director

PO Box 2429

Sidney, British Columbia V8L 3Y3

Email: chris@raincoast.org
21

Appendix A

Relevant Recent Coyote Population Research and Related Literature

Berger, K.M. 2006. Carnivore-livestock conflicts: effects of subsidized predator control and 

economic correlates on the sheep industry. Conservation Biology 20(3):751-761.

Bromley, C., and E. M. Gese. 2001. Effects of sterilization on territory fidelity and maintenance, 

pair bonds, and survival rates of free-ranging coyotes. Canadian Journal of Zoology 

79:386-392.

Brainerd, S.M., H. Andren, E.E. Bangs, E.H. Bradley, J.A. Fontaine, et al. 2008. The effects of 

breeder loss on wolves. Journal of Wildlife Management 72: 89–98.

Conner, M. M., M. M. Jaeger, T. J. Weller, and D. R. McCullough. 1998. Effect of coyote 

removal on sheep depredation in northern California. Journal of Wildlife Management 

62:690-699.

Crabtree, R. 2012. Scientific Opinion Letter: "What effect does reduction of coyotes (older than 6 

months) have on the remaining population?" 5 pages. URL: 

http://www.projectcoyote.org/wpcontent/uploads/2015/05/Crabtree_coyote_letter_PC_April_2013.pdf.

Crabtree, R.L., and J.D. Varley. 1995. The ecological and sociodemographic role of the coyote 

on Yellowstone’s Northern Range. Pp. 63-84, In Proceedings of the 3rd biennial science 

conference on the Greater Yellowstone Ecosystem, Greater Yellowstone’s Predators. 

Yellowstone National Park and Northern Rockies Conservation Cooperative, Mammoth, 

WY.

Crabtree, R.L., and J.W. Sheldon. 1999. The ecological role of coyotes on Yellowstone's 

Northern Range. Yellowstone Science 7:15-24.

Crooks, K.R., and M.E. Soule. 1999. Mesopredator release and avifaunal extinctions in a 

fragmented system. Nature 400:563-566.

Estes, J.A., et al. 2011. Trophic downgrading of planet earth. Science 333: 301–306.

Gehring, T. M., K. C. VerCauteren, and J.-M. Landry. 2010. Livestock Protection Dogs in the 

21st Century: Is an Ancient Tool Relevant to Modern Conservation Challenges? 

BioScience 60(4):299-308.

Gehrt, S.D., S.P.D. Riley, and B.L. Cypher (Eds). 2010. Urban carnivores: ecology, conflict, and 

conservation. Johns Hopkins University Press, Baltimore, MD.

Gese, E. M. 1998. Response of neighboring Coyotes (Canis latrans) to social disruption in an 

adjacent pack. Canadian Journal of Zoology 76: 1960-1963.

Gese, E. M., R. L. Ruff, R. L. Crabtree. 1996. Foraging ecology of coyotes (Canis latrans): the 

influence of extrinsic factors and a dominance hierarchy. Canadian Journal of Zoology 

74:769-783.

Gilbert, S.L., K.J. Sivy, C.B. Pozzanghera, A. DuBour, K. Overduijn, M.M. Smith, J. Zhou, J.M. 

Little, and L.R. Prugh 2016. Socioeconomic benefits of large carnivore recolonization 

through reduced wildlife-vehicle collisions. Conservation Letters 

DOI: 10.1111/conl.12280. 

Harrison, D. J. 1992a. Dispersal characteristics of juvenile coyotes in Maine. Journal of Wildlife 

Management 56: 128-138.

Harrison, D.J. 1992b. Social ecology of coyotes in northeastern North America: Relationships to 

dispersal, food resources, and human exploitation. Pages 53-72 in A. H. Boer, editor. 
22

Ecology and management of the Eastern Coyote. Wildlife Research Unit, University of 

New Brunswick, Fredericton, Canada.

Henke, S.E., and F.C. Bryant. 1999. Effects of coyote removal on the faunal community in 

western Texas. Journal of Wildlife Management 63:1066-1081.

Hornocker, M., and S. Negri, 2010. Cougar Ecology & Conservation. The University of Chicago 

Press, Chicago, USA.

Knowlton, F. F., E. M. Gese, and M. M. Jaeger. 1999. Coyote depredation control: an interface 

between biology and management. Journal of Range Management 52: 398-412.

Mech, L. D., and L. Boitani, editors. 2003. Wolves: behavior, ecology, and conservation. 

University of Chicago Press, Chicago, Illinois, USA.

Mezguida, E.T., S.J. Slater, and C.W. Benkman. 2006. Sage-grouse and indirect interactions: 

potential implications of coyote control on sage-grouse populations. The Condor 

108:747-759.

Mitchell, B.R., M.M. Jaeger, and R.H. Barrett. 2004. Coyote depredation management: Current 

methods and research needs. Wildlife Society Bulletin 32: 1209-1218.

Parker, G.R. 1995. Eastern Coyote: The Story of Its Success. Nimbus Publishing, Halifax, NS.

Patterson, B.R., and F. Messier. 2001. Social organization and space use of coyotes in eastern 

Canada relative to prey distribution and abundance. Journal of Mammalogy 82:463-477.

Peebles, K.A., R.B. Wielgus, B.T. Maletzke, and M.E. Swanson. 2013. Effects of remedial sport 

hunting on cougar complaints and livestock depredations. PloS ONE. DOI: 

10.1371/journal.pone.0079713. 

Poessel, S.A., E.M. Gese, and J.K. Young. 2017. Environmental factors influencing the 

occurrence of coyotes and conflicts in urban areas. Landscape and Urban Planning 157: 

259–269.

Povilitis, T. 2016. Compassionate Conservation for Yellowstone's Wolves. Nature Areas Journal 

36(3): 334-338.

Proulx, G., and D. Rodtka. 2015. Predator Bounties in Western Canada Cause Animal Suffering 

and Compromise Wildlife Conservation Efforts. Animals 5:1034-1046.

Ramp, D., and M. Bekoff. 2015. Compassion as a Practical and Evolved Ethic for 

Conservation. BioScience 65: 323-327.

Ripple, W.J., J.A. Estes, R.L. Beschta, C.C. Wilmers, E.G. Ritchie, M. Hebblewhite, J. Berger, 

B. Elmhagen, M. Letnic, M.P. Nelson, O.J. Schmitz, D.W. Smith, A.D. Wallach, and A.J. 

Wirsing. 2014. Status and ecological effects of the world’s largest carnivores. Science

343: 151–162.

Sacks, B. N., K. M. Blejwas, and M. M. Jaeger. 1999a. Relative vulnerability of coyotes to 

removal methods on a northern California ranch. Journal of Wildlife Management 

63:939-949.

Sacks, B. N., M. M. Jaeger, J. C. C. Neale, and D. R. McCullough. 1999b. Territoriality and 

breeding status of coyotes relative to sheep predation. Journal of Wildlife Management 

63:593-605.

Sargeant, G. A., and R. L. Ruff. 2001. Demographic response of Black Bears at Cold Lake, 

Alberta, to the removal of adult males. Ursus 12: 59-68.

Stolzenberg, W. 2008. Where the wild things were: life, death, and ecological wreckage in a 

land of vanishing predators. Bloomsbury USA, New York. 291 pages.

Treves, A., G. Chapron, J.V. Lopez-Bao, C. Shoemaker, A.R. Goeckner, and J.T. Bruskotter. 

2015. Predators and the Public Trust. Biological Reviews 92: 248-270.
23

Treves, A., M. Krofel, and J. McManus. 2016. Predator control should not be a shot in the dark. 

Frontiers of Ecology and Environment 14(7): 380–388, doi:10.1002/fee.1312

Van Eeden, L. M., et al. 2017. Managing conflict between large carnivores and livestock, 

Conservation Biology, doi: 10.1111/cobi.12959

Vucetich, J., and M.P. Nelson. 2014. Wolf hunting and the ethics of predator control. Political 

science, comparative politics, political theory. Oxford, UK: Oxford Handbooks Online.

Wallach, A.D., M. Bekoff, M.P. Nelson, and D. Ramp 2015. Promoting predators and 

compassionate conservation. Conservation Biology 29: 1481-1484.

Wallach, A. D., E. G. Ritchie, J. Read, and A.J. O’Neill. 2009. More than mere numbers: the 

impact of lethal control on the social stability of a top-order predator. PloS ONE 

4(9):e6861:1-8.

Way, J.G. 2007. Movements of transient coyotes (Canis latrans var.) in urbanized eastern 

Massachusetts. Canadian Field-Naturalist 121(4): 364-369.

Way, J. G. 2010. Double-litters in Coywolf (Canis latrans x lycaon) Packs Following the Death 

or Disappearance of a Resident Territorial Male. Canadian Field Naturalist 124(3): 256-

257.

Way, J.G. 2011. Eastern Coyote/Coywolf (Canis latrans x lycaon) Movement Patterns: Lessons 

Learned in Urbanized Ecosystems. Cities and the Environment (CATE) 4(1): article 2, 12 

pages. http://digitalcommons.lmu.edu/cgi/viewcontent.cgi?article=1044&context=cate.

Way, J.G., and B.N. White. 2013. Coyotes, red foxes, and the prevalence of Lyme disease. 

Northeastern Naturalist 20(4):655-665. 

Way, J. G., I.M. Ortega, and P.J. Auger. 2002. Eastern coyote home range, territoriality and 

sociality on urbanized Cape Cod, Massachusetts. Northeast Wildlife 57: 1-18.

Way, J. G., B.C. Timm, and E. G. Strauss. 2009. Coywolf (Canis latrans x lycaon) pack density 

doubles following the death of a resident territorial male. Canadian Field Naturalist 

123(3): 199-205.

Wielgus, R.B., and K.A. Peebles. 2014. Effects of Wolf Mortality on Livestock Depredations. 

PLoS ONE 9(12): e113505. doi:10.1371/journal.pone.0113505.